Product Requirements: RoHS, PFOS and Environmental Indicators

Transcription

1 Product Requirements: RoHS, POS and Environmental Indicators SESHA, North Texas Chapter September 2008 Tim Yeakley

2 RoHS - Product Stewardship Mark rimann Tim Yeakley

3 Legislative Requirements Towards Product Stewardship EU RoHS - The European Union Restriction of Hazardous Substances in Electronic and Electrical Equipment Directive 2002/95/EC is the most well know law EEE industry law Released 23 Jan 2003, enacted 1 July 2006 Restricts the use of 6 substances at defined maximum concentration values (MCVs) 0.1% for Pb, Hg, Cr6+, PBB & PBDE, 0.01% for Cd Exemptions for defined applications 2008 updates: Review exemptions and evaluating 46 new substances Other countries have enacted similar RoHS laws China, Japan, California (USA), South Korea, Thailand, India with others in development More than just RoHS 6 substances WEEE recycling requirements Montreal Protocol (CCs) Application specific: Automotive (End of Life Vehicle), Packing, wood products, plastics, labeling requirements, etc. REACH: process and finished product chemical content & use It s important to understand the legislative requirements to provide proper product stewardship responses to customers

4 Customer Requirements (Meeting RoHS and other Product Stewardship requests) Product stewardship questions to meet RoHS and other legislation coming from customers is as wide and varying as the customer base Simple requests Yes / No to EU RoHS 6 Use EU defined MCVs / exemptions Negative declaration requests List of substances not to be contained above MCVs If contained, where and how much Most complex requests Report all substances within a product Declare to customer s list of banned and/or reportable substances RoHS 6 substances up to 580+ other substances Maximum Concentration Values (MCVs) defined by customer 3 rd party test reports (commonly called ICP reports) RoHS 6 plus Bromine & Chlorine + (35+ other material groups) Updated yearly for each homogeneous subcomponent Certificates of Compliance (CofCs) Legal documents requiring signatures & conformance to customer specs

5 Challenges of Meeting Green Requirements our major areas continue to be challenging for the supply chain Consistent MCVs defined by regulations required up and down the supply chain Practical homogeneous definition for small components Due diligence practices 3rd party test report frequency of updates Regulations with consistent definitions shared in all regions/countries/local legislation

6 Consistent MCVs Customer MCVs for the RoHS 6 are inconsistent Supplier #13 requirements copied by suppliers #2 and #12 Dropping in plastics becomes a big issue (impossible?) to meet Supplier #14, example, must meet Regulations, have check threshold

7 Homogeneous Material set examples Homogeneous material sets for basic lead frame products Homogeneous material sets for basic BGA products

8 Homogeneous across all IC components Pics of IC examples Blow-up of 10 Euro Cent with ICs on it Homogenous info for all sizes required

9 Due Diligence Practices 3rd Party Testing As part of due diligence to show products are compliant, having data stating a component is compliant is not enough Actual test data to back up these claims is becoming required Downstream suppliers are writing into their specs test data for the RoHS 6 banned substances at the homogeneous level The biggest issue is requirements being pushed to have these reports < 12 months old AND resent every year for each homogeneous material A lead frame device requires 5 or more homogeneous test reports Each report likely has a different date the material was tested Resubmissions could occur 5 (or more) times every year or a component supplier with > products and thousands of customers, this is not just impractical, it becomes impossible

10 Consistency in Regulations Regulations addressing product stewardship should be as harmonized as possible Most component suppliers are global in their downstream supply base As new substances come into play: Methods to achieve compliance must be developed Address required applications and/or exemptions Consistency as a key into implementing practical solutions

11 POS Policy Issues and Plans

12 POS What is it? O POS is a PBT (Persistent, Bioaccumulative Toxin) ound to be widely distributed in the blood serum: polar bears and EU ministers Used as a Photoacid Generator in some resists or as a surfactant resistant to intense energy used in litho and with good refractive index characteristics What is POA? Replace the Sulfonate head w/carboxylic acid Sometimes used to replace POS in some resists and ARC s Probably a PBT - EPA is still determining toxicity issues What is PAS? Sulfonated with varying chain lengths Sometimes used to replace POS (i.e. PBS) Toxicity is unproven S O X

13 PAS Homologue amily Lower Homologues Higher Homologues C 1 C 4 C 5 C 7 C 8 C 9 C n n = 0 to 3 n = 4 to 6 n = 7 n = 8 to n POS is a member of the class of PAS chemicals in which the sulfonyl group is attached to a fully fluorinated alkyl chain consisting of 8 carbon atoms. Note: EPA s POS SNUR includes some, but not all, substances in commerce that share that common chemical profile.

14 POS Industry Actions SIA members worked with Sematech to develop technical information SIA agreed on a set of actions that would minimize use of POS. SIA developed information use to support a US PAS exemption ESIA developed information used to support a EU POS exemption SIA sponsored a voluntary agreement in 2004 that requires all World Semiconductor Council (WSC) companies to: Incinerate residues Eliminate non-litho uses Seek alternatives for litho uses Research control technology Report progress The WSC adopted the agreement in 2005 and reported progress in 2008 SIA/ESIA/SEMI hired a treaty consultant to help negotiate our position JEITA/JSIA is working to understand their risk issues and convey their concerns to their government.

15 POS Agency Actions irst restricted via USEPA SNUR in 2002 ollowed with additional PAS chemicals added. EU followed suit with a Marketing and Use Directive (MUD) in 2004 The UN has proposed a ban on POS as a Persistent Organic Pollutant (POP) that is preceded by 2 regulatory activities Long Range Transboundary Air Pollution (LRTAP) Treaty Stockholm Convention on POPs POS could be banned from manufacture, use or both in the signatory countries (some exemptions may be allowed) The Japanese Chemical Substance Control law is currently structured such that if a chemical is part of the Stockholm Convention, it will banned for manufacture or use in Japan regardless of any exemptions allowed.

16 LRTAP s POP s Annexes Annex I - Banned Aldrin P/D Chlordane P/D Chlordecone P/D DDT P*/D Dieldrin P/D Endrin P/D Heptachlor P/D* Hexabromobiphenyl P/D Hexachlorobenzene P*/D* Mirex P/D PCB P*/D Toxaphene P/D Annex II Restricted DDT for public health uses & and as chemical intermediate HCH (Lindane) use as chemical intermediate and several other public health related exceptions PCB Exempt with phase out push to using countries Annex III Monitor, etc. PAH s Dioxins/furans Hexachorobenzene P=Production U=Use - Special Conditions RED letters = Stockholm chemicals

17 Stockholm s POP s Annexes Annex A - Banned Annex B Restricted Aldrin P/D DDT for public Chlordane P/D health uses & and as Dieldrin P/D chemical Endrin P/D intermediate Heptachlor P/D* Hexachlorobenzene P*/D* Mirex P/D PCB P*/D Toxaphene P/D Annex C Unintentional PCDD/PCD (dioxins and dibenzofurans) Hexachlorobenzene PCB s (Polychlorinated biphenyls) P=Production U=Use * - Special Conditions

18 Timeline of POS events LRTAP s Stockholm Nominated by Sweden August EB Agrees to review December POP T prepares Management Options Paper June 06 to June 07 Nominated by Sweden mid- 05 WGSR with ether a) Recommend more work by the TPOP on options ore b) recommend listing by EB Review Management Options Sept 07 POPRC reviews nomination Nov 05 to Nov 06 EB reviews WGSR recommendation Dec 07 If no decision to list TPOP further develops management options June 08 POPRC collects Socio-economic information and control options Nov 06 to eb 07 POPRC prepares draft Risk Management Evaluation eb 07 to May 07 WGSR reviews management options and makes recommendation to EB Dec 08 Draft RME s open for public Comment June 07 RME inalized and reviewed by POPRC July- Nov 07 EB decides to list Dec 08 POPRC finishes review in Nov 07 meeting and forms recommendations or decides to keep working until Nov 08 Cop reviews POPRC recommendation and adopts amendments to add POS to the Annex May 2009

19 LRTAP, Stockholm & POP s Stockholm POPs Convention eb 10, 2007 Apr 6, 2007 Drafter (EC) Prepares Working Risk Mgmt Evaluation May 25, 2007 Secretariat Distributes Draft Risk Mgmt. Evaluation for comment Jun 30, 2007 Aug 10, 2007 Ad Hoc Working Group Considers Comments and Prepares Revised Draft Risk Mgmt Evaluation Nov 19, Nov 23, 2007 POPRC-3 Discusses Draft Risk Mgmt Evaluations Apr 7, 2007 May 10, 2007 Ad Hoc Working group Develops Draft Risk Mgmt Evaluations Opportunity to participate as an observer Jun 29, 2007 Oct 12, 2007 eb 9, 2007 Annex Submittal Deadline Apr 30, 2007 May 4, 2007 COP-3 Meeting Comments due on Draft Risk Mgmt. Evaluation Secretariat Distributes inal Draft Risk Mgmt. Evaluation eb '07 Mar '07 Apr '07 May'07 Jun '07 Jul '07 Aug '07 Sep '07 Oct '07 Nov '07 Dec '07 Apr 18, 2007 Apr 20, 2007 LRTAP POPs Convention WGSR 39 th Session (Heads of Delegation) Sep 17, 2007 Sep 21, 2007 WGSR 40 th Session Dec 10, 2007 Dec 14, 2007 EB Meeting Mar 1, 2007 Jun 4, 2007 Task orce develops Mgmt Options eb 28, 2007 Annex Questionnaire Due Jun 4, 2007 Jun 6, 2007 Task orce Meeting to discuss Draft Mgmt Options

20 LRTAP, Stockholm & POP s Amendment will enter into force (i.e., become legally effective) one year later in May The amendment will be legally binding on all parties to the Convention except those that: (a) have indicated their non-acceptance during the one-year interval; or (b) have previously indicated at the time that they joined the treaty that they will not be bound by any amendments unless they affirmative express their intention to be bound. It is possible that some countries' domestic laws may change automatically upon the adoption of the amendment and the listing of POS in the treaty. It is possible that some countries may not have in place domestic regulations to implement their obligations under the Convention, even if they are legally obligated under the Convention to do so. Stockholm POPs Convention Oct 13 th -Oct 17 th 2008 POPRC 4 - inal language will be decided for listing as Annex A, B, and/or C Oct 13 th -Oct 17 th 2008 COP 4 - inal language adopted for listing as Annex A, B, and/or C Apr '08 May'08 Jun '08 Jul '08 Aug '08 Sep '08 Oct 08 Nov '08 Dec '08 May '09 LRTAP POPs Convention Apr 14, 2008 Apr 17, 2008 WGSR 41st Session Annex I or Annex II? EU Annex I and Canada and US are pushing for Annex II Sept 1, 2008 Sept 5, 2008 Dec 10, 2007 Dec 14, 2007 WGSR 42nd Session Language will be reviewed for forward to the EB for a listing decision. Annex I or Annex II? EU is voting for Annex I, US and Canada are promoting Annex II EB Meeting Language will likely be adopted adding POS to the Annex I or Annex II list Amendment will enter into force when 2/3 of the Parties to the Protocol ratify the amendment. This will require 20 parties to submit ratification letters. That is likely to take ~ 2-3 years. The amendment will be legally binding only on those parties that have ratified the amendment. It is possible that EU will amend its internal legislation sooner to make the amendment effective. This would affect all 27 EU member states.

21 Risks Potential loss of supply Production interruptions or qualifications of alternatives Equipment modifications may be necessary at high cost Technology development may be impacted POA may be next PAS?

22 What now The SC industry has developed an advocacy plan that includes: A one-page backgrounder for the SC industry A document that described impact to industry in Japan A contact matrix by country We are working with several governments to make them aware of the potential impact to the SC industry of this issue. We are asking them to protect their concerns in the upcoming conference of the parties.

23 Key Environmental Performance Indicators An alternative to Life Cycle Assessment Customers are starting to pull

24 Environmental Indicators Issue Environmental Life Cycle Assessment (LCA) of products: mfg & use Drivers Energy - use and CO 2 e, Water - input vs. output, Raw Materials use Chemical and other (targets, silicon, etc), Wastes chemicals, solid, and hazardous Energy Using Products (EuP) Directive Korea s KOECO COOL Project (CO 2 Low) Japan s CO 2 Labeling project consumer goods

25 Environmental Indicators EuP - ramework Directive Applies to household and consumer equipment White goods, table or countertop portable appliances TV s, audio, video, games, phones, etc. LCA is one of the requirements dormant but not forgotten Japan s CO2 labeling Seems to be targeting consumables now ood, cleaning supplies, etc. Korea s COOL Labeling CO 2 and energy Gov t sponsored voluntary program

26 Korea s KORECO COOL (CO 2 Low)

27 Key Environmental Performance Indicators ISMI project Currently working with EU, US, Japan & Korean IDM s Develop short list of product metrics and accounting guidelines Water use Chemical use Waste generation Greenhouse gas generation Debate continues about accounting protocol Won t include: product transportation End of life Goal create a usable guideline for accounting

28 Backup

29 Marketing and Use Directive Signed by European Parliament in October 2006 Members countries will now implement legislation to enact the directive as-is Similar in effect to the USEPA SNUR exemption for critical uses No time limit for review Specific to POS compounds No de minimus criteria (<0.1ppm) ESIA had to touch this all the way through the process to ensure the relevant information was available to all the decision makers

30 Recent History PNEC established in 2007 Predicted No Effects Concentration By German government or use within REACH for surface water discharge limits POS 2ug/L POA 20ug/L